# T037 — ASP Active-Investigation-Only Image Policy vs 150-Day HIDTA Retention ASP's December 2024 policy manual republishes an effective-2011 ALPR rule that limits captured-image maintenance to open or active investigations. Six months later, ASP's ELSAG vendor confirmed that every ASP camera in HIDTA was configured for 150-day retention. The records do not establish whether the older patrol-unit policy governed the later fixed/HIDTA architecture, whether a successor policy existed, or how routine 150-day storage was reconciled with the image-file sentence. ## Statement A LE SEC 28 states: > "Image data files captured will only be maintained for an open/active criminal investigation." ([[ASP ALPR Policy Retention and FOIA Exemption Proposal]], `ASP Policy Manual - Mike Hagar, Director_Secretary (1).pdf`, PDF p. 344). The PowerDMS transmittal says the December 2024 manual replaced prior manuals, while the page itself remains effective 2011-10-12. ## Statement B On 2025-06-04, [[Robert Ryan]] told [[Dennis Overton]]: > "ALL ASP cameras in HIDTA are set to 150 day data retention." ([[ASP ALPR Policy Retention and FOIA Exemption Proposal]], `RE_ Data Retention.msg`). The HIDTA template separately says state law controls a member agency's retention period ([[ASP HIDTA Governance Terms and Administrator Duties]], `HHIDTA LPR MOU 11.15.22 _Secure.pdf`, p. 11; `Houston HIDTA LPR Policy 11.15.22_Secure.pdf`, p. 2). ## Why it matters The difference affects which written rule governed routine plate-image storage, which records should show implementation, and whether the public-facing policy matched the configured system. A 150-day ceiling under state law is not itself inconsistent with shorter local retention, but a universal 150-day configuration is difficult to square with an unqualified active-investigation-only sentence unless the provisions address different data, hardware generations, or preservation stages. ## Resolution status **Open.** Resolution requires the operative 2024-2025 ALPR policy and any successor/supersession record; configuration history; purge logs; definitions distinguishing captured image files, plate-read records, alerts, and case-preserved evidence; and records showing how the HIDTA setting was implemented. ## Discovery Surfaced during the 2026-07-28 remaining-communications ingest by reading `RE_ Data Retention.msg` against PDF page 344 of the attached ASP policy manual. ## Notes This is distinct from [[T007 - ASP No-LPR-System Position vs Documented ELSAG Operation|T007]], which concerns whether ASP operated an ALPR system at all. T037 assumes the system existed and asks which retention rule governed it.